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｢정부행정｣ 제10권(2014): 103-148Journal of Government Administration, Vol.10 (2014)

The Rhetoric and the Reality of the Legal Guarantee for Freedom of Information:

A Cross-National Study on the Level of Freedom of Information

Nam, Taewoo**1)

Abstract

Analyzing the longitudinal data combining several global indices, this paper

empirically examines what factors determine the degree to which a country achieves

freedom-of-information ideals – access to information, press freedom, and

transparency. Though countries with a freedom-of-information law show greater

achievement of freedom-of-information ideals, the presence or absence of the

legislation itself is not significant for estimating accomplishment of the ideals after

controlling both time-series and cross-sectional effects. Such determinants as the

general quality of public administration and socio-political stability proved significance

as an explanatory variable in the panel data regressions. Countries with Scandinavian

and German legal traditions are higher achievers of freedom-of-information ideals than

those with English and French heritages. From a narrow focus on the subsample of

countries with a freedom-of-information law, the study found that not merely the

intention behind a particular provision but also concreteness and specificity of the

statute significantly affect achievement of the legal ideals.

Key Words: Freedom of information; Access to information; Right to know;

Transparency; Openness; Freedom of press

Ⅰ. Introduction

A law pursues to actualize our desires for a better society. The

legislation for freedom of information (FOI) is a specific expression of

legal protection for the right to know. We expect the law to make a

* Assistant Professor of the Department of Public Administration at Myongji University

104 ｢정부행정｣ 제10권(2014)

government more accountable and transparent via a broader avenue to

approaching governmental information, to which citizens and the press are

more easily accessible. In this sense, I identify FOI ideals as the public’s

access to information, freedom of press and transparency.

Amongst about 210 countries on our globe, only 73 countries have the

law that legally stipulates freedom of information. This plain fact leads to

skepticism of global FOI. We should say that if an FOI law (FOIL) itself

is an effective tool to realize FOI ideals, merely one third of all countries

promise freedom of information. However, the level of the effectiveness of

the law, despite plausibility of the general tendency that countries with an

FOIL are high achievers of FOI ideals, varies from country to country.

Furthermore, not all countries with an FOIL do achieve the legal ideals

successfully. If an FOIL per se is actually symbolic and mythical in spite

of its legal guarantee for FOI ideals, it has no better than nominal values.

With such skeptical consideration of FOI realities in a global context, I

raise a simple research question involving the rhetoric and the reality of

an FOIL: What determines the realization of FOI ideals in global

societies?

I hypothesize that the general quality of public administration,

socio-political stability and legal tradition serve as a more important

determinant for the degree of fulfilling FOI ideals than the simplistic fact

that an individual country has or does not have an FOIL. Focusing on

countries that have an FOIL, I expect the difference in FOIL features

would make a distinction between high achievers and low achievers of

FOI ideals. For a cross-national study, this paper, employing the panel

data regressions and analysis of variance (ANOVA) as main

methodologies, statistically analyzes the longitudinal data generated by

merging several worldwide indices from 2001 to 2008. The paper starts

with reviewing core arguments in previous studies. After expatiating on the

The Rhetoric and the Reality of the Legal Guarantee for Freedom of Information 105

panel data and variables employed, its main parts report key findings and

implications from statistical analyses. The final sections address limitations

of this cross-national empirical study and conclusive remarks.

Ⅱ. Ideals and Realities of FOI Laws

Since Sweden’s pioneering adoption of an FOIL in 1776, there has been

a long temporal lag until a global spread of the legislation during recent

decades. With a tidal wave of democratization over the globe, the impetus

factors like anti-corruption movement, international pressures, further

modernization and societal informatization have triggered consideration of

an FOIL as the necessity for democracy (Banisar, 2006). The law states

the right of access to information (ATI) in order to make government

accountable. It can be effective in three levels. In the basic level, it

prevents a government from interfering with information dissemination. Its

middle level requires a government to comply with citizens’ demands on

governmental information. On the more mature stage of an FOIL regime,

we expect a government’s affirmative obligation to inform public. Each

level of these hierarchical goals may be either a desired state for some

countries or a current reality for others. The gulf between ideals and

realities differentiates a group of greater FOI countries from the other

group of less FOI ones.

1. FOI ideals: Right-to-know, press freedom and transparency

FOI is regarded as a basic human right (Perritt & Lhulier, 1997;

Piotrowski & Rosenbloom, 2002). The fundamental purpose of an FOIL is

106 ｢정부행정｣ 제10권(2014)

to give the public the right to know and define a legal framework for the

sharing of information (Islam, 2006). The law has provided “an engine

that makes publicly available much of the vast and otherwise inaccessible

storehouse of government information” (Gellman, 1997). The right to

access to government-held information is a cornerstone of representative

democracy (Mendel, 2008). As with the First Amendment to the United

States Constitution, the Freedom of Information Act (FOIA) purports to

“promote democratic-constitutional values including transparency and

individual rights” (Piotrowski & Rosenbloom, 2002).

An FOIL is an essential tool to ensure democratic control of

government. Feinberg (2004) identified the FOIA as “a logical extension of

decades-long efforts to hold government agencies accountable for their

decisions.” Without the right of access to information, a citizen’s ability to

participate actively in policy deliberations or hold public institutions

accountable for their conduct is compromised and even constrained. By

signifying reduction in restrictions imposed on information flow (Islam,

2006), an FOIL keeps people aware of policymaking processes (North,

1999) and the value of public information (Chongkittavorn, 2002). In the

United States, the FOIA has been practiced to increase governmental

transparency and advance accountability (Piotrowski & Rosenbloom, 2002

). The British expectation for the legislation goes toward eroding cultural

and institutional secrecy by making the government more open (Worthy,

2008).

Main users and beneficiaries of an FOIL are the public and the media.

Improved access to official records has not been granted only to an

amorphous populace but to the press as the most influential champion for

the law (Relyea, 1979). An FOIL holds little value for citizenry without

free media (Martin & Feldman, 1998); thus, free press is a precondition

to enhance citizens’ right to know. A FOIL’s legal protection of the right


to know helps the press perform its reportorial and journalistic work of

documenting governmental activities in public interests (Rush, 1986).

2. Determinants for FOI realities: Administration, stability, legal heritage, and provisions

FOI statutes are so widely diffused that they have come to resemble

“rationalized institutional myths” (Meyer & Rowan, 1991). Aside from

practices of implementing an FOIL, the broad provisions provide myths

and symbols to demonstrate that a country legally supports good values

– i.e. freedom of information, transparency, openness and democratic

control – for public administration. The legal rhetoric is similar across

countries with an FOIL. The FOIA of the United States has been a

template for other countries that prepare for a new FOIL, and thus most

FOILs around the world are much alike under the influence of such a

model law (Mendel, 2008). However, the interpretation and application of

an even identical provision may vary with country, culture, regime and

polity because of differences in administrative quality and disparities in

social, cultural and legal contexts. This divergence can be a reason for the

dissonance between our desires for FOI ideals and the current reality.

Having an FOIL is not enough to ensure that it is effective (Foerstel,

1999; Islam, 2006; Roberts, 2000). The nominal existence of the law

cannot be any hallmark for its successful implementation. Government

agencies must be required to publish information, and there must be some

mechanisms to implement the law effectively. Gellman (1997) identified

problems inherited in the FOIA as three facets: 1) poorly drafted, 2)

inadequately funded, and 3) unenthusiastically implemented. As the undue

level of flexibility and administrative discretion is problematic for

implementation, manifold problems with the FOIA are administrative

108 ｢정부행정｣ 제10권(2014)

rather than legislative.

In Commonwealth countries with longer histories of FOI legislation, the

creation of a FOI regime has not ended secrecy within a government

(Roberts, 2005). When considering the historical fact that the FOIA in the

United States was legislated in the face of enormous opposition by the

executive branch, less effective and less committed implementation of the

law has no wonder. Though today’s climate is not as hostile as the

executive branch in the earlier FOIA regime was (Relyea, 2009), public

agencies seldom have rigid motives for faithful administration of the

statutes. Lombard’s (2007) experiment on 408 local public bodies’

responses to information requests at the state of Illinois reported that an

average citizen encounters blatant resistance, numerous delays and arbitrary

obstructions, which violate the original spirit of the FOIA and the state

FOIL.

Regarding that information is a fragile, time-sensitive commodity

(Feinberg, 1986), a delayed and inconsistent response is a frequent

complaint of the press who needs the information in time for a deadline

(Rush, 1986). Worthy (2008) found sources of inconsistency and tardiness

in the low quality of administration and information management.

Inextricably entwined in a larger context of information policy, an FOIL is

an object of management and implementation apart from its normative

ideals (Feinberg, 1986). The degree to which the FOI ideals are fulfilled

depends on administrative discretion to implement the laws (Darch &

Underwood, 2005; Davis, 2000; Feinberg, 2004; Halstuck, 2000; Islam,

2006). A key to realization of FOI goals is the change in attitude within

agencies in regard to FOIA administration (Relyea, 1979).

Another problem that public administration faces in implementing an

FOIL arises from the ongoing mantra of public entrepreneurialism. Since

the emergence of the New Public Management (NPM) paradigm, public


administrators and managers have rejected a conventional stress on

processes and democratic-constitutional values in favor of results

(quantifiable performance measures). The businesslike management trend

categorizes process-oriented actions to implement an FOIL as nonessential

and noncore missions, especially in terms of budget priority (Piotrowski &

Rosenbloom, 2002; Roberts, 2000). The reinvention movement may

undermine laws that give citizens the right of access to government

information.

In addition to the quality of public administration, the FOI reality is

not independent of socio-political conditions and a legal infrastructure.

Political stability affects the degree to which the rule of a law is

effectively and seamlessly implemented and enforced. In the reverse way, a

national FOIL represents a crucial opportunity to consolidate stability of a

country (Mistry, 2006). Accordingly, the level of domestic socio-political

stability has a positive influence on the accomplishment of FOI ideals.

Legal tradition is a rudimental background to determine the degree to

which FOI ideals are realized. The influence between law and society is

reciprocal. While a law affects societies and culture, a country’s legal

framework evolves with diverse social, cultural factors. Legal tradition may

change over time due to information exchange across different cultures

and societies. A case law acts as a driver of internal information

exchange; meanwhile, globalization is an external catalyst for variability in

legal tradition. Institutionalized legal heritage, nevertheless, reflects a solid

socio-cultural context that a country has maintained for long. Most

countries largely fall into several branches of legal tradition: common law

tradition (American or British) and civil law tradition (Roman, German or

French). Although specific provisions in a national FOIL have a great

resemblance across countries that lately benchmarked some influential

models of FOI legislation in the Western world, the reference to disparate

110 ｢정부행정｣ 제10권(2014)

legal traditions will distinguish the pattern in interpretation and application

of a similar FOIL.

The last determinant for FOI reality is a specific feature of an FOIL.

What items the law is armed with can be an important predictor for

explaining the level of FOI ideals accomplishment. FOILs vary in scope

(the degree of specificity and applicability) from country to country. Some

laws are very detailed regarding what information is kept secret under

what circumstances, and others are quite general (Martin & Feldman,

1998). As Gellman (1997) pointed out, the reason why FOI ideals are not

achieved may be a problem inherent in provisions. Along with other

factors, statute specificity will determine the level of FOI reality.

Ⅲ. Methods and Measurements

Based on the discussion of FOI ideals and realities, I raise a research

question: “What determines the extent to which ideals of an FOI law are

realized?” FOI ideals that this study focuses on include access to

information (ATI) as an individual citizen’s right to know, freedom of the

press, and a government’s transparency. As a set of explanatory variables

to estimate the level of FOI realities, the general quality of public

administration, socio-political stability, legal tradition and FOIL features

will present an answer to the research question.

1. Dataset

This study constructs a new panel dataset by merging multiple

secondary longitudinal datasets that consist of various yearly country-level

indicators. Analyzing panel data instead of cross-sectional data allows us


to know the impact of focal explanatory variables on dependents while

controlling for year-specific and country-specific noisy influences.

Additionally, the increased number of observations will reduce the

possibility of violating the normality assumption and mitigate a potential

problem from the lack of data in particular years and units of the original

datasets.

<Table 1> The number of countries included in each index

Dependent variables Independent variables

Freedom House 1

TransparencyInternational(CorruptionPerceptionIndex) 2

GlobalIntegrityIndex 3

Worldwide Governance Indicators 4

Worldwide Governance Indicators 4

from(Porta et al.,

2008; Djankov et al., 2003) 5

from(Tromp, 2008) 6

YearPress

freedomTransparency ATI Public Admin Stability Legal FOIL’s

2001 186 90 – – – 188 2162002 193 102 – 197 190 188 2162003 193 132 – 197 200 188 2162004 194 145 25 204 207 188 2162005 194 155 – 204 208 188 2162006 194 163 41 206 209 188 2162007 194 180 50 207 209 188 2162008 – 180 46 – – 188 216Total 1,348 1,147 162 1,215 1,223 1,504 1,728

Source 1: http://www.freedomhouse.org/template.cfm?page=1Source 2: http://www.transparency.org/policy_research/surveys_indices/cpiSource 3: http://www.globalintegrity.org/data/downloads.cfmSource 4: http://www.govindicators.orgSource 5: http://www.economics.harvard.edu/faculty/shleifer/paperSource 6: http://www3.telus.net/index100/foi

As shown in Table 1, both dependent variables and independent

variables have different data sources. The indicator of press freedom is

acquired from Freedom House online. Transparency International annually

provides the indicator of national corruption. This index has been broadly

used as a proxy for national transparency in previous cross-national

studies. The open dataset that Global Integrity releases presents surveys

pertinent to a citizen’s access to government information in limited number

112 ｢정부행정｣ 제10권(2014)

of countries (Appendix 3). I derived the quality of public administration

and political stability from World Bank’s Worldwide Governance

Indicators (WGI). This study imported the taxonomy of legal heritages

categorized in the political-economics papers of Porta, Lopez-de-Silanes

and Shleifer (2008) and Djankov, Porta, Lopez-de-Silanes and Shleifer

(2003). Based on Tromp’s (2008) study, I generated a set of dummy

variables germane to FOIL features.

2. Methodology

The study employs four regression techniques as a main methodology to

analyze the panel data: 1) a simple OLS model without time dummy

variables; 2) an OLS model with time dummies; 3) a random effects

model (REM) or an error-components model (ECM) estimated by

generalized least square (GLS); and 4) a fixed effects model (FEM) to

consider time-specific and country-specific effects. The model

specifications are as follows.

For i-th country and t-th year,

R = realization of FOI ideals F = FOIL dummy (1 if a country has an FOIL)

Q = quality of public administration S = socio-political stability

L = legal tradition dummies T = year dummies

C = country dummies

The first model (OLS estimation in a pooled data) does not allow us to

know both the change in a dependent variable over time and the variation


in the dependent across countries at a given point in time. Estimates in

the second model, despite inclusion of time variables, are likely to be still

inflated and consistently biased due to inconsideration of hidden

cross-sectional effects. Thus, the best regression model for analyzing this

panel data is selected between FEM and REM.

Two panel data techniques have differential assumptions. While FEM

adds dummies (both Ci0 and T0t) to allow for the changes in the

cross-sectional and time-series intercepts, REM assumes error terms are

correlated across years and individual countries (Pindyck & Rubinfeld,

1997). REM treats an intercept term in FEM as two random components

(time-series error v0t and cross-sectional error ui0). The basic assumptions

underlying both models do not perfectly fit this panel data; reversely

saying, the dataset partially match both assumptions. If error terms and

regressors are correlated, FEM should be preferred over REM (Gujarati,

2002). Since I expect the size of error terms moves with the variation in

independents like the quality of public administration or political stability,

FEM would be more appropriate than REM. In the meantime, the

inclusion of binary variables (FOIL dummy and legal tradition dummies)

with a value constant over years substantially decreases an overall level of

the correlation between regressors and error terms. Accordingly, the

decline in the correlation between error terms and regressors weakens

imperativeness of selecting FEM. Moreover, the REM assumption is

tenable with the expectation that the error variance is correlated across

specific years and individual countries (heteroskedasticity).

Gujarati (2002) recommended that when the number of time-series data

is small but the number of cross-sectional units is large (the same

situation as in this dataset), REM is appropriate if the cross-sectional

units in the sample are regarded as random drawings from a much larger

population. However, the global dataset does not meet the REM

114 ｢정부행정｣ 제10권(2014)

assumption of random sampling because a group of available countries in

the whole sample is almost the same as the population. REM,

nevertheless, has a practical appeal from using up fewer degrees of

freedom as well as a conceptual appeal from broad characterization of the

sources of error (Pindyck & Rubinfeld, 1997). A practical problem of

FEM in analyzing this panel dataset is that it drops some of critical main

variables due to the collinearity between multiple dummies.

There is a simple rule for a choice between FEM and REM. The

Hausman test recommends we select FEM when we can reject the null

hypothesis that slope coefficients are equal between both models (Gujarati,

2002). Nonetheless, I cannot hinge on the convenient criterion without

consistency in both underlying assumptions. Since there is no last resort to

select one of two models, I consider both. Still, the panel data techniques

provide more meaningful implications and more precise (consistently

unbiased) estimates than an OLS model in a simply pooled data.

Along with this main methodology, I rely on ANOVA to examine the

significance of the mean difference in FOI achievement scores across

groups of countries (between countries with an FOIL and those without

the law, and among disparate legal traditions). Contingency tabulation and

charts will illustrate the cross-group difference.

3. Dependent variables: ATI, press freedom and transparency

Dependent variables represent three ideals of an FOIL discussed in the

previous section. The first variable is the level of citizens’ access to

government information. I employ five sub-indicators of Global Integrity

Index in 2004, 2006, 2007 and 2008. A newly created index is an average

of the following five percentage-scale scores: 1) “In practice, citizens


receive responses to access to information requests within a reasonable

time period”; 2) “In practice, citizens can use the access to information

mechanism at a reasonable cost”; 3) “In practice, citizens can resolve

appeals to access to information requests within a reasonable time

period”; 4) “In practice, citizens can resolve appeals to information

requests at a reasonable cost”; and 5) “In practice, the government gives

reasons for denying an information request.”

The second dependent variable is an index of press freedom provided

by Freedom House. It is an aggregate of three sub-indicators: 1) laws

and regulations that influence media contents; 2) political pressures and

controls on media contents; and 3) economic influences over media

contents. The summated score has a percentage scale. Islam (2006) found

that the presence of an ATI law is positively correlated with press

freedom and negatively correlated with journalist abuse. The indicator of

press freedom is expected to have a substantial correlation with whether a

country has an FOIL.

The third dependent variable is governmental transparency or openness,

which refers to the ability to find out what is going on inside government

(Piotrowski & Ryzin, 2007). I adopt Transparency International’s

Corruption Perception Index (CPI) as a proxy for the level of national

transparency. An individual country’s CPI score indicates the degree of

public sector corruption as perceived by business experts and government

analysts. An original value (interval scale) of the index ranges between 0

(highly corrupt) and 10 (highly clean and transparent). For visible

comparability with other dependent variables, I also use the

percentage-scale transformation (multiplied by 10) of the index. The

cross-national study by Relly and Sabharwal (2009) provides a ground for

adopting the three indicators as dependent variables, showing that

countries ranked as most transparent have significantly a higher level of

116 ｢정부행정｣ 제10권(2014)

mass media freedom and legal protection for ATI.

<Table 2> Descriptive statistics in 2007 data

Variable N of obs Mean Std. Dev. Min MaxPRESS FREEDOM 194 53.469 24.367 2 91TRANSPARENCY 180 3.993 2.090 1.401 9.423Access-to-information [ATI] 50 0.424 0.242 0 0.851*FOIL 216 0.333 0.472 0 1PUBLIC ADMINISTRATION 207 0 1 -2.374 2.188STABILITY (z-score) 209 0 1 -3.010 1.650*Legal tradition: ENGLISH 188 0.324 0.469 0 1*Legal tradition: FRENCH 188 0.532 0.500 0 1*Legal tradition: GERMAN 188 0.101 0.302 0 1*Legal tradition: SCANDINAVIAN 188 0.027 0.161 0 1*Legal tradition: SOCIALISM 188 0.016 0.126 0 1FOI-related variablesSpecificity 79 6.443 2.500 0 11History (the number of years) 72 11.708 12.027 0 61*Constitution 79 0.734 0.445 0 1*Who request 79 0.937 0.245 0 1*Anyone request 79 0.658 0.477 0 1*Citizen request 79 0.278 0.451 0 1*Fee 79 0.646 0.481 0 1*How to request 79 0.722 0.451 0 1*How to response 79 0.899 0.304 0 1*Public interest override 79 0.570 0.498 0 1*Officials’ duty 79 0.646 0.481 0 1*Officials’ penalty 79 0.494 0.503 0 1*Other laws override 79 0.810 0.395 0 1*Affirmative disclosure 79 0.759 0.430 0 1*Policy advice exemption 79 0.342 0.477 0 1*Cabinet record exemption 79 0.241 0.430 0 1*Whistleblower protection 79 0.139 0.348 0 1

*: binary variable (dummy)Note 1: Public administration and stability are measured in z-score. Note 2: Specificity of an FOIL is an aggregate of 11 binary items so that it has a minimum of 0 and a maximum of 11.

4. Independent variables: FOIL, administration, political stability and legal tradition

Including a dummy variable of whether a country has an FOIL is

important because its coefficient can signify the difference between FOIL

countries and no-FOIL countries. Also, this categorical variable is


necessary for finding out the relationship between the presence of the law

and the real level of FOI. Studies to date have regarded the presence of

the law as a dummy variable. Relly and Sabharwal (2009) examined

whether the presence of an ATI law influences business executives’

perceptions of national transparency in government policymaking. Using an

FOIL dummy, Islam’s (2006) analysis concluded the presence of an FOIL

affects governance. Unlike in other studies, the sample of FOIL countries

in this study includes countries – Argentina, China, Hong Kong, Pakistan

and Philippines – that have similar legal provisions as a form of code or

regulation though it is not exactly an FOIL. The longitudinal dataset

includes the latest FOIL joiners – Chile (2008), Cook Islands (2008),

Indonesia (2008), Jordan (2007), Nepal (2007), and Nicaragua (2007).

<Table 3> Collinearity between WGI indices

Variable Variation Influential Factor (VIF) Tolerance (1/VIF)WGI: Government Effectiveness 19.61 0.0510WGI: Rule of Law 16.80 0.0595WGI: Control for Corruption 14.01 0.0714WGI: Regulatory Quality 10.16 0.0984WGI: Political Stability 1.98 0.5051Mean VIF 12.53 –

<Table 4> Scoring by factor analysis

VariableFactor 1

(Eigenvalue = 3.71)Factor 2

(Eigenvalue = 0.03)Uniqueness

WGI: Government Effectiveness 0.9789 0.0623 0.0379WGI: Rule of Law 0.9583 -0.0811 0.0751WGI: Control for Corruption 0.9644 -0.0977 0.0603WGI: Regulatory Quality 0.9480 0.1170 0.0877

Focusing on the gap between legal ideals and realities, this study

hypothesizes factors influencing FOI realities are more significant than the

FOIL dummy. There are three influential factors. First, the general quality

of public administration will affect the level to which a country

118 ｢정부행정｣ 제10권(2014)

accomplishes the ideals. WGI provides four indicators related to public

administration. Table 3 describes substantial collinearities among its

sub-indicators. Four indicators (i.e., how effectively a national government

is operated, how well the rule of law is implemented, how well the public

sector controls corruption, and how well a regulation is implemented)

have too high correlation (low tolerance) to be included together in a

model (Table 3). They are combined into one score by factor scoring

(Table 4). I name the newly created score as Public Administration.

Contrary to other government-related WGI indicators, Political Stability

that has a lower VIF (less serious collinearity) is independently adopted as

another main explanatory variable to be a proxy for socio-political

stability in an individual country.

The third force to affect FOI ideals is legal tradition, which evolves

within a social context, and thus it reflects changes in society and culture.

This study employs the categorization of legal tradition used in the studies

by Djankov et al. (2003) and Porta et al. (2008). In their categorization,

all legal traditions fall into five heritages: English, French, German,

Scandinavian, and Socialist. Countries categorized into English heritage (the

United States and Commonwealth countries following Westminster

tradition) are regarded as to have common law tradition (Djankov et al.,

2003; Porta et al., 2008).

5. Independent variables: FOIL features

While an FOIL dummy may significantly differentiate between FOIL

countries and no-FOIL countries, multiple characteristics of an FOIL may

help explain significantly differences across countries within an FOIL

group. Thus, these variables are employed to answer the question of

“What FOIL features have an important influence on FOI ideals?” Across


countries, an FOIL has a common set of diverse provisions, but some

items bring fundamental differences in legal provisions. Except the history

of FOIL, I coded all FOIL features as a dichotomous status of yes (1) or

no (0).

FOIL history The history of an FOIL is to find out whether

countries with the law in presence for longer years are more likely to

raise the level of ATI, press freedom and governmental transparency. It is

measured as the number of years since the passage by subtracting the

adopted year (Appendix 1) from a specific year in the panel dataset. To

eliminate Sweden’s potential leverage as an outlier, I used the year of

revision (1949) instead of the precursor year of 1776 in global FOIL

history. Sweden, despite such transformation, is still the oldest FOIL

country in the dataset. Columbia that adopted a law on access as

prematurely as in 1885 is also suspected of another leverage as an outlier.

The initial law has been unused for a century until the year of 1985

when the modern law was established (Banisar, 2006). In my dataset, the

adopted year of Columbia is coded as 1985. Since most countries have

short history except some advanced countries, I use the first adopted year

in each FOIL country instead of a revision year.

Specificity Concreteness or specificity of an FOIL is measured by the

number of particular provisions (among 11 items that this study focuses

on) that it has. In addition to the ordinal variable, the study uses its

dichotomous transformation. If a country has more provisions than 6, the

binary variable is coded as 1 (more specific), and as 0 (less specific) for

otherwise.

Constitutional guarantee The constitutional status of FOI is a legal

precondition to protect specific statues of an FOIL constitutionally

(Tromp, 2008). If the national constitution states the public’s right to

know, this variable is coded as 1, and as 0 for otherwise.

120 ｢정부행정｣ 제10권(2014)

Who may ask (“Anyone can request,” “Only citizen can request”) A

majority of countries allow anyone to ask for information regardless of

citizenship, residence or interests (Banisar, 2006). Whereas there are

countries allowing for anonymous requests, some countries require a

requester to show proof of citizenship. This study uses two binary

variables: “anyone can request” and “only citizens can request.” Both are

mutually exclusive. If an FOIL has either one, the variable for the

provision of “who may ask” is coded as 1.

Fee Demanding fees from requesters limit the ability of the less well

off to ask for information. The premise “fees are barriers” existed as early

as in the time of Reagan administration (Feinberg, 1986). Governments’

attempts to sell information and increase FOI fees may create economic

barriers to openness (Roberts, 2000). With the aggressive pursuit of new

sources of nontax revenue, NPM governments in the United States have

attempted to package and sell information instead of releasing it at low

costs in response to FOI requests (Piotrowski & Rosenbloom, 2002). A fee

provision can reduce requests to a substantial degree so that a

government’s economic motive deters citizens and the press from exercising

their FOI rights. By imposing new fees on applications and appeals,

Ireland experienced the decline in the number of requests by half (Banisar,

2006). Commodification of government information may be a threat to

openness. The absence or presence of a fee provision is an important

dummy variable to predict the level of realizing FOI ideals.

How to request and How to response An FOIL in some countries

lacks description of procedures of request and response. Without

explanation of the step-by-step process from request to disclosure, the

FOIL may be no more than its title. Concreteness of the described

schedule will be correlated to performance of the law. If an FOIL

describes how to request and how to response, the variables would have a


value of 1.

Public interest override The provision of public interest override is

crucial for governmental transparency because it limits the scope of

exemptions. Public interest test requires public authorities to balance the

interest in withholding information against the public interest in disclosure

(Banisar, 2006). The provision contains the following items for public

interest test: 1) Should the provision apply to all statutory exemptions?;

2) Should it override exemptions absolutely? Or should other needs be

weighed and balanced against it?; and 3) Should the state have a duty to

proactively publish such information? (Tromp, 2008). If a country has a

clear provision about these items, this variable is coded as 1.

Duty to publish One of common principles in an FOI regime is an

obligation to publish; that is, public bodies should be under an obligation

to publish key information (Mendel, 2008). While some information is

routinely released, other information is proactively published under the

FOIL (Tromp, 2008). If an FOIL includes officials’ duty to publish

government-held information, the variable has a value of 1.

Noncompliance penalty The presence of a penalty provision is a vital

factor for greater openness (Tromp, 2008). A feature of FOILs designed to

encourage open administration is the sanctions provision to punish the

arbitrary and capricious withholding of documents (Gellman, 1997). Reylea

(1979) identified threatening penalties for the arbitrary or capricious

withholding of records as a key driver for faithful execution of an FOIL.

Without severe penalties, transparency requirements are merely aspirational

(BGA, 2002, 2008). The relevant provision stipulates penalties for officials

who destroy, falsify records, or delay, refuse responses to requests. If an

FOIL includes a penalty provision for officials’ noncompliance with the

law, the variable is coded as 1.

Other laws override Whether an FOIL allows other laws to override

122 ｢정부행정｣ 제10권(2014)

the statute on information release is a critical provision. Especially, a

secrecy provision related to national defense may override an FOI statute.

This variable is coded as 1 when an FOIL contains a provision that other

laws override it.

Affirmative disclosure An active provision of information publication

is a common feature of most FOILs (Banisar, 2006). Proactive disclosure

of government-held information implies voluntary, routine publication of

non-requested information. If a government releases particular information

without having to make an FOI request, the variable is coded as 1.

Policy advice exemption Unlike other FOIL exemptions of privacy

and national defense, an exemption for policy advice seems “innocuous”

(Tromp, 2008). This exemption is based on the assumption that the

actions and decisions of a government should not withstand too much

exposure. The public’s access to records on policy development might

hinder policymaking processes because “the threat of public scrutiny would

curb free and frank discussion, inhibit the candor of advice, and therefore

seriously hamper the smooth running of government” (Tromp, 2008). The

presence of the exemption for policy advice is coded as 1, no matter how

the provision is broad or narrow.

Cabinet records exemption Strict cabinet secrecy is a strong tradition

in Commonwealth countries (Tromp, 2008). Some specific types of cabinet

documents are excluded for cabinet confidences in FOIL applications. If an

FOIL has the provision of cabinet records exemption, the variable is

coded as 1.

Whistleblower protection This provision offers legal protection for

individuals who release information on wrongdoing (Mendel, 2008). It

would facilitate the disclosure of information on negative activities (corrupt

practices or mismanagement) in public agencies and give people an

incentive to come forward without fear of being sanctioned for their


disclosures (Banisar, 2006). If an FOIL contains a whistleblower protection

provision, this variable is coded as 1, otherwise as 0.

Ⅳ. Analysis

1. Between-group comparison

As illustrated in Figure 1, the mean difference between FOIL countries

and no-FOIL countries is significant in three dependent variables. FOIL

countries show a consistently higher level of citizens’ ATI, press freedom

and governmental transparency than no-FOIL countries. This trend

corresponds to the general tendency (significant χ2 statistics) in frequency

distribution in Table 5, but findings from conditional contingency in the

cross-tabulation are not as promising for FOI ideals as a simplistic mean

comparison in Figure 1 is.

<Figure 1> The mean difference in dependent variables between

FOIL countries and No-FOIL countries (% scale, 2007 data)

[ ] = Standard Deviation

124 ｢정부행정｣ 제10권(2014)

In Table 5, 29% of FOIL countries fall in high ATI group; whereas,

merely 6% of no-FOIL countries are categorized as high level of ATI.

The percentage distribution of FOIL vs. no-FOIL in the lowest level of

ATI (83%:17%) is opposite to that in the highest ATI group (18%:82%).

However, while 60% of FOIL countries lie in a middle level of ATI, the

equal proportion in the no-FOIL group takes the low level of ATI. The

percentage of high ATI countries in the FOIL group is not as great as

that of low ATI countries in the no-FOIL group. Thus, the significance in

the mean difference does not necessarily imply a sharp contrast of FOIL

vs. no-FOIL countries.

The distribution in the press freedom index is more supportive for the

effectiveness of an FOIL than that in the ATI index. While 55% of FOIL

countries have free press, only 27% of no-FOIL countries have free press.

The FOIL vs. no-FOIL contrast is also sharp in the not-free category,

but the frequency in the ideal (free) state is less desirable than that in the

non-ideal (not-free) state. In the not-free state of press freedom, the

ratio of FOIL to no-FOIL countries is 13%:87%; whereas, the ratio in

the free state is 54%:46%. The distribution in the ideal state does not

correspond to our high expectation for the positive impact of an FOIL on

press freedom.

Despite a general tendency of high transparency in FOIL countries, the

frequency in transparency is almost evenly distributed between the middle

(38%) and the high (40%) level. The contingency tabulation between

transparency and FOIL exhibits that in spite of the significant p-value in

the χ2 statistic, the middle vs. high contrast (38%:40%) in the FOIL

group is not as sharp as the frequency difference between low and high

transparency (46%:28%) in the same group. In no-FOIL countries, the

frequency is also equal between the middle (28%) and the high (26%)

level. Hence, t and χ2 statistics serve as a more lenient criterion to signify


the between-group difference than the comparison between cell

percentages in the cross-tabulation is.

<Table 5> Contingency between the FOIL dummy and dependent variables

(Row/Column/Cell %)χ2=42.30, pr=0.000

Practices of ATI (panel)

Low (0-33) Middle (34-66) High (67-100) Total

FOIL 10 (12/18/6) 50 (60/65/31) 24 (29/83/15) 84 (100/–/52)

No FOIL 46(59/82/28) 27 (35/35/17) 5 (6/17/3) 78 (100/–/48)

Total 56 (–/100/34) 77 (–/100/48) 29 (–/100/18) 162 (100/100/100)


Press freedom (2007)

Not free Partly free Free Total

FOIL 8 (11/13/4) 24 (34/41/12) 39 (55/54/20) 71 (100/–/37)

No FOIL 55 (45/87/28) 35 (28/59/18) 33 (27/46/17) 123 (100/–/63)

Total 63 (–/100/32) 59 (–/100/30) 72 (–/100/37) 194 (100/100/100)


Transparency (2007)

Low Middle High Total

FOIL 16(22/20/7) 27 (38/40/13) 29 (40/43/13) 72 (100/–/33)

No FOIL 66 (46/80/30) 40 (28/60/19) 38 (26/57/18) 144 (100/–/67)

Total 82 (–/100/37) 67 (–/100/32) 67 (–/100/31) 216 (100/100/100)

<Figure 2> The mean difference in dependent variables across

legal heritages (% scale, 2007 data)

[ ] = Standard DeviationNote: There is no ATI data of countries with Scandinavian and socialist legal heritage.

126 ｢정부행정｣ 제10권(2014)

On the other hand, Figure 2 portrays the mean difference in three

dependent variables across legal traditions. Overall, countries with

Scandinavian and German legal heritage have a higher level of indices.

English and French traditions have a within-group mean value around a

grand mean (total average). The between-tradition mean difference is

significant in all three variables. English and French groups have more

mean-droppers decreasing the average level or more outliers than

Scandinavian and German groups do. The distribution within English and

French groups, thus, reflects heterogeneity across countries with the same

legal tradition.

Charts and contingency tabulation sketch the visible distinction across

disparate groups – between FOIL countries and no-FOIL countries, and

among differential legal tradition groups. The hitherto analysis by

conditional frequency and mean comparison, however, does not bring a

valid evidence for the impact of an FOIL on achievement of its goals. I

posit determinants for FOI realities have a significant influence on

realization of FOI ideals. The next sections, presenting the result of

regression analyses on the panel data, test the significance of determinants

for estimating the level of ATI, press freedom and transparency.

2. Access to information

Table 6 describes the result of regressions for predicting the ATI level

for the whole sample. Whether a country has an FOIL is not significant

for estimating the ATI level when controlling for time-series and

cross-sectional effects. In the FEM that controls hidden effects from

individual countries and particular years, the presence of an FOIL does

not have an independent explanatory power. The impact of an FOIL

dummy on the ATI level is substantially diminished by direct or indirect


influences from year-specific and country-specific effects (influences by

omitted variables related to year or country).

<Table 6> Regressions of ATI for all countries

Simple OLS OLS with time FEM REM

FOIL 16.174† (3.778) 16.006† (3.783) 11.273 (16.157) 15.698† (4.013)

PUBLIC ADMIN 11.294** (3.318) 10.994** (3.333) 7.297(37.733) 11.229**(3.517)

STABILITY 0.970 (2.600) 0.782 (2.604) 10.022(15.817) 0.883(2.748)

ENGLISH -14.942* (6.713) -14.736* (6.718) Dropped -14.509* (7.105)

FRENCH -6.546 (6.420) -6.383 (6.424) Dropped -5.869 (6.780)

GERMAN Dropped Dropped Dropped Dropped

SCANDINAVIAN Dropped Dropped Dropped Dropped

year2006 – -3.526 (3.636) -3.135(4.269) -3.364(3.453)

Constant 77.322† (11.169) 78.371† (11.224) 69.445**(19.943) 76.064† (11.115)

N of obs 113 113 113 113

N of groups – – 71 71

Adjusted R2 0.4551 0.4548 0.3930 0.4886

F or χ2 F=16.59 (pr=0.00) F=14.35 (pr=0.00) F=0.87 (pr=0.51) χ2=89.24 (pr=0.00)

Hausman test – – χ2=1.27 (pr=0.94)

*: pr < 0.05, **: pr < 0.01, †: pr < 0.001Note: Dummy variables other than year2006, ENGLISH and FRENCH are dropped due to collinearity.

On the other hand, political stability is not a predictor for an individual

citizen’s ATI in all models. With the exception of FEM, the quality of

public administration is significant at the 1% level. Amongst legal

traditions, only English heritage is significant. The sign and magnitude of

the slope coefficient implies that as shown in an overall lower mean value

of an English heritage group in Figure 2, English tradition has a lower

score of ATI by 14.5 than German and Scandinavian tradition – here,

two dropped variables are a comparison category. The result of the

Hausman test supports preference of REM over FEM. The GLS estimation

of REM is almost the same as OLS estimation. Under the REM

assumption that an error term changes with respect to year and country,

the FOIL dummy, public administration and the English-tradition dummy

are a set of significant regressors to estimate ATI for all countries.

128 ｢정부행정｣ 제10권(2014)

The result of regression of ATI for the FOIL sample in Table 7 is

slightly different from Table 6. REM for the subsample still shows

significance of the quality of public administration, but its significance

drops to the 5% level. English tradition loses its significance. In this

model, public administration is solely a significant predictor for explaining

the level of citizens’ ATI. As in the regression of a whole sample, the

Hausman test suggests reliance on REM. However, this result lacks

efficiency of the regression estimates due to the small number of

observations and many degrees of freedom. Notwithstanding, it is

invariable that public administration is a more important variable than

others are.

<Table 7> Regressions of ATI for the FOIL subsample


PUBLIC ADMIN 11.947* (4.633) 11.938* (4.706) 4.077(61.382) 12.315*(5.067)

STABILITY 0.336 (4.856) 0.332 (4.911) 1.891(19.872) -0.033(5.255)

ENGLISH -15.385 (8.890) -15.372 (9.020) Dropped -15.076 (9.772)

FRENCH -6.981 (7.462) -6.990 (7.553) Dropped -7.236 (8.155)

GERMAN Dropped Dropped Dropped Dropped


year2006 – -0.104 (5.576) -1.964(6.568) -0.484(5.271)

Constant 84.362† (14.868) 84.398† (15.146) 77.624**(21.947) 83.981† (14.881)

N of obs 55 55 55 55


Adjusted R2 0.2632 0.2479 0.2562 0.3310



Note: Dummy variables other than year2006, ENGLISH and FRENCH are dropped due to collinearity.

3. Press freedom

Despite a general tendency of the similar result between OLS on the

pooled data and REM on the panel data, REM for estimating press


freedom drops a significance of the FOIL dummy. Though the Hausman

test recommends using FEM, its dropping of all legal traditions allows for

attention to REM. Legal heritage dummies are all significant in predicting

the level of press freedom. The magnitude is directly comparable. The

slope magnitude of Scandinavian and German traditions is much larger

than that of English and French traditions. The Scandinavian vs.

non-Scandinavian difference is as high as 64.6 scores.

The contrast between FEM and REM is notable in the variable of

public administration. When controlling for country-specific and

year-specific effects in FEM, the quality of public administration is not a

significant variable any more. However, with the REM assumption of

heteroskedasticity caused by year-variant and country-variant error terms,

public administration is highly significant in a modest positive magnitude.

Here, assumptions grounding both models are equally appealing to this

panel dataset. Thus, I underscore a common finding from two models.

Political stability is, in spite of the different level in significance, an

important predictor for estimating press freedom.

Regressions for the FOI subsample in Table 9 exhibit a dramatic change

in slope coefficients on legal tradition dummies. Not only OLS models but

also REM loses the significance level. Furthermore, the sign of English and

French dummy, despite insignificance of the coefficients, shifts from positive

to negative. This implies legal traditions do not significantly affect the level

of press freedom in the FOIL subsample. As like the result for the whole

sample, the Hausman test selects more appropriateness of FEM. In both

FEM and REM, political stability in countries with an FOIL is a significant

explanatory variable for predicting press freedom. The significance of public

administration fundamentally differentiates between FEM and REM.

Socio-political stability is persistently important in estimating press freedom

no matter how an individual country has an FOIL.

130 ｢정부행정｣ 제10권(2014)

<Table 8> Regressions of press freedom for all countries


FOIL 9.853† (1.198) 9.853† (1.200) 0.129 (0.634) 0.591 (0.647)

PUBLIC ADMIN 9.068† (0.867) 9.068† (0.869) 1.709(0.923) 5.444† (0.835)

STABILITY 7.508† (0.778) 7.508† (0.779) 1.117*(0.505) 1.594** (0.509)

ENGLISH 35.478† (3.863) 35.478† (3.871) Dropped 45.921† (9.437)

FRENCH 31.364† (3.774) 31.364† (3.781) Dropped 37.221† (9.306)

GERMAN 32.932† (4.080) 32.932† (4.087) Dropped 51.403† (9.932)

SCANDINAVIAN 32.832† (5.024) 32.832† (5.033) Dropped 64.628† (11.844)

year2003 – 0.070 (1.500) -0.061(0.303) -0.070(0.316)

year2004 – -0.102 (1.422) -0.181(0.287) -0.158(0.300)

year2005 – 0.040 (1.419) -0.026(0.287) -0.019(0.300)

year2006 – 0.077 (1.487) 0.086(0.300) 0.087 (0.313)

Constant 21.068† (3.951) 21.074† (4.093) 54.784† (0.368) 13.361 (9.200)

N of obs 1,077 1,077 1,077 1,077

N of groups – – 181 181

Adjusted R2 0.6005 0.5990 0.5312 0.4793



Note: Collinearity among dummies drops all legal tradition variables in FEM.

<Table 9> Regressions of press freedom for the FOIL subsample


PUBLIC ADMIN 10.848† (0.912) 10.842† (0.918) -2.153(1.582) 5.572† (1.215)

STABILITY 8.023† (0.970) 8.035† (0.978) 5.871† (0.867) 6.337† (0.873)

ENGLISH 4.718* (2.039) 4.717* (2.051) Dropped -0.538 (3.467)

FRENCH 2.535 (2.116) 2.536 (2.128) Dropped -6.217 (3.256)

GERMAN 4.385* (2.105) 4.381* (2.117) Dropped Dropped

SCANDINAVIAN Dropped Dropped Dropped 4.436 (5.325)

year2003 – 0.176 (1.695) 0.549(0.408) 0.277(0.476)

year2004 – 0.179 (1.523) 0.326(0.381) 0.522(0.435)

year2005 – 0.382 (1.435) 0.232(0.378) 0.402(0.407)

year2006 – 0.360 (1.444) 0.086(0.300) 0.207 (0.405)

Constant 58.407† (2.441) 58.275† (2.798) 69.536† (0.975) 67.098† (2.741)

N of obs 349 349 349 349


Adjusted R2 0.7912 0.7888 0.4558 0.7516



Note: Collinearity among dummies drops all legal tradition variables in FEM.


4. Transparency

Regressions of transparency reveal an apparent difference between the

OLS models and the panel data models. The significance in both the

FOIL dummy and political stability distinguishes results by simple OLS

models from results by panel data techniques. Whether a country has an

FOIL is not a significant variable in the panel data regressions. While

political stability loses its significance in both panel data models, public

administration consistently has a significant influence on transparency.

Three legal tradition dummies are significant at 5% level, but their sign is

negative despite a moderate impact in magnitude of the slope coefficients.

Instead of considering a negative sign on the dummies, the coefficients are

interpreted as the relative distances in score of the proxy for transparency

across legal heritages because they make a difference in intercepts.

<Table 10> Regressions of transparency for all countries


FOIL -0.159** (0.052) -0.160** (0.052) 0.104(0.074) 0.040(0.064)

PUBLIC ADMIN 2.153† (0.041) 2.156† (0.041) 0.591† (0.157) 1.912† (0.066)

STABILITY -0.109** (0.039) -0.111** (0.039) -0.059(0.073) -0.081(0.054)

ENGLISH -1.262† (0.212) -1.272† (0.212) Dropped -1.042* (0.431)

FRENCH -1.274† (0.207) -1.285† (0.207) Dropped -1.080* (0.423)

GERMAN -1.432† (0.217) -1.445† (0.217) Dropped -1.203** (0.447)

SCANDINAVIAN -0.226 (0.250) -0.240† (0.250) Dropped Dropped

year2003 – -0.103 (0.076) -0.073(0.040) -0.107*(0.042)

year2004 – -0.055 (0.068) -0.041(0.037) -0.068(0.038)

year2005 – 0.093 (0.065) 0.030(0.034) 0.056(0.036)

year2006 – 0.028 (0.065) 0.022 (0.034) 0.023(0.036)

Constant 5.267† (0.215) 5.357 (0.226) 4.160 (0.051) 5.184† (0.425)

N of obs 866 866 866 866

N of groups – – 177 177

Adjusted R2 0.9163 0.9165 0.8921 0.9147

F or χ2 F=1,184 (pr=0.00) F=792 (pr=0.00) F=2.65 (pr=0.007) χ2=2,009 (pr=0.00)

Hausman test – – χ2=101.79 (pr=0.00)

Note: The dummy of Scandinavian tradition is dropped due to collinearity in REM.

132 ｢정부행정｣ 제10권(2014)

With the rejection of the null hypothesis that FEM and REM are not

systematically different, the χ2 statistic by the Hausman test supports a

better fit of FEM in estimation of the transparency level. If the equivalent

significance of FEM and REM in model fitness allows us to accept

simultaneously the basic assumptions behind the two models, the quality

of public administration remains as a significant determinant for

governmental transparency.

The result of running the subsample is not different from that in a

whole sample. Public administration is significant across models. Legal

traditions are significant, but have a negative sign reflecting a relative

distance to an average of a comparison group. A noteworthy difference

between the whole sample and the subsample appears at the coefficient on

stability in REM. Its negative sign gains the significance in the subsample.

This does not indicate political stability negatively correlates with

transparency in countries with an FOIL. Table 12 reveals that high

pairwise correlation between political stability and transparency have

positive Pearson correlation coefficients in both the FOIL subsample

(r=0.74) and the whole sample (r=0.73).

Differently to reasonable coefficients in pairwise correlation, partial

correlation delivers results that may be counterintuitive. When controlling

other independent variables, the partial correlation coefficient of political

stability on transparency is negative but marginally small in its absolute

value. Moderately high pairwise correlation between transparency and

stability disappears in partial correlation due to the lockstep relation

among multiple variables included in regression. This mismatch between

partial correlation and pairwise correlation can be the compelling evidence

that public administration is a consistently important estimator for

predicting governmental transparency, but socio-political stability is not.


<Table 11> Regressions of transparency for the FOIL subsample


PUBLIC ADMIN 2.356† (0.069) 2.359† (0.070) 0.866† (0.245) 2.197† (0.110)

STABILITY -0.251** (0.074) -0.258** (0.075) -0.194(0.130) -0.222*(0.104)

ENGLISH -0.709† (0.151) -0.710† (0.151) Dropped -0.929** (0.316)

FRENCH -0.940† (0.155) -0.943† (0.155) Dropped -1.208† (0.325)

GERMAN -1.181† (0.154) -1.182† (0.155) Dropped -1.325† (0.320)


year2003 – -0.096 (0.123) -0.090(0.064) -0.128(0.068)

year2004 – -0.158 (0.112) -0.139*(0.060) -0.171**(0.062)

year2005 – 0.023 (0.107) -0.045(0.057) -0.038(0.060)

year2006 – -0.034 (0.107) -0.036 (0.056) -0.050(0.059)

Constant 4.686† (0.179) 4.793† (0.205) 4.821† (0.147) 5.128† (0.315)

N of obs 340 340 340 340


Adjusted R2 0.9290 0.9287 0.9131 0.9297

F or χ2 F=740.19 (pr=0.00) F=442.65 (pr=0.00) F=2.86 (pr=0.007) χ2=1,082 (pr=0.00)


Note: The dummy of Scandinavian tradition is dropped due to collinearity.

<Table 12> Pairwise and partial correlation with transparency

Correlation PubicAdministration

PoliticalStability English French German Scandinavian

PairwiserY*Xi (All)

0.946(pr=0.000)

0.734(pr=0.000)

0.093(pr=0.002)

-0.327(pr=0.00)

0.141(pr=0.000)

0.436(pr=0.000)

Pairwise rY*Xi (FOIL)

0.955(pr=0.000)

0.743(pr=0.000)

0.166(pr=0.000)

-0.390(pr=0.000)

-0.058(pr=0.223)

0.503(pr=0.000)

Partial rY*Xi|X’s (All)

0.881(pr=0.00)

-0.073(pr=0.033)

-0.198(pr=0.00)

-0.205(pr=0.000)

-0.227(pr=0.000)

-0.037(pr=0.275)

Partial rY*Xi|X’s (FOIL)

0.881(pr=0.00)

-0.185(pr=0.001)

-0.250(pr=0.00)

-0.315(pr=0.000)

-0.386(pr=0.000) Dropped

The negative pairwise correlation is not necessarily counterintuitive. A

high level of political stability can have the tendency to reduce the

pressure for governmental openness, which is often motivated by the need

to keep an eye on a political opponent. In the United States history, FOIA

arose from conflict between the Democratic Congress and the Republican

president. The carrying-over Congress espoused the principle of openness

even when the Presidency shifted to the Democratic Party, much to

134 ｢정부행정｣ 제10권(2014)

President Johnson’s chagrin. The lesson penetrating through this historical

fact is that though a general tendency is that socio-political stability

enhances the level of FOI ideals, politicians and the public under instable

politics may actively and strongly push a government toward greater

openness.

5. FOIL features

Although most FOIL countries have followed a role model of an FOIL,

specific provisions vary with individual countries. Table 13 illustrates FOIL

features with the respect to a legal tradition. Scandinavian countries own

far longer history of an FOIL than other legal heritage groups do. The

specificity of an FOIL, measured by the number of provision items

considered in this study, significantly differentiates one tradition from the

others. FOILs with English tradition are more specific.

65% of French-tradition countries have a fee provision while a third

quarter of English and German heritage countries contain the provision in

their FOIL. Notably, no Scandinavian country has a fee provision.

Considering that fees may act as a barrier against FOI, the absence of a

fee provision can partly explain a consistently high level of Scandinavian

FOI scores. However, no fee-provision has two meanings: 1) like

Scandinavian countries, a national government does not impose any fee

(literally free request); or 2) the lack of the provision may be just an

evidence of a poorly drafted FOIL if fees are actually imposed to an

information requester in administrative practices.


<Table 13> FOIL features with the respect to a legal tradition

FOIL featuresLegal tradition

TotalEnglish French German Scandinavian

History (F=17.74)† 11.9 years 10.0 years 8.4 years 41.4 years 11.7 years

Specificity (F=9.15)† 8.5 items 5.3 items 6.7 items 5.6 items 6.5 items

Constitution (χ2=1.88) 75% 76% 88% 60% 73%

Who can request (χ2=6.46) 100% 85% 100% 100% 94%

How to request (χ2=3.85) 80% 65% 88% 60% 72%

How to response (χ2=4.78) 95% 82% 100% 80% 90%

Anyone request (χ2=2.70) 60% 62% 81% 80% 66%

Only citizen request (χ2=2.62) 40% 24% 19% 20% 28%

Fee (χ2=10.91)* 75% 65% 75% 0% 65%

Public interest override (χ2=13.05)** 85% 35% 63% 60% 57%

Duty (χ2=11.68)** 90% 47% 75% 80% 65%

Penalty (χ2=7.91)* 75% 47% 38% 20% 49%

Other laws override (χ2=9.36)* 90% 65% 94% 100% 81%

Affirmative disclosure (χ2=1.71) 85% 74% 75% 60% 76%

Policy advice exemption (χ2=17.84)† 70% 15% 31% 20% 34%

Cabinet record exemption (χ2=21.97)† 60% 9% 6% 40% 24%

Whistleblower protection (χ2=7.37)* 30% 15% 0% 0% 14%

*: pr < 0.05, **: pr < 0.01, †: pr < 0.001

Public interest override, officials’ duty, penalty for officials, other laws

override, policy advice exemption and cabinet record exemption show a

remarkable difference among the four legal traditions. While 85% of

English-tradition countries have a provision of public interest override,

only 35% of French-tradition countries have it. The proportion of

countries that have the provision to stipulate public officials’ duty to

publish government information is 90% in the English tradition, but

merely 47% in the French tradition is. This pattern also appears in the

penalty provision and the other-laws-override provision. The low

proportion in German and Scandinavian heritage countries has a penalty

provision. While almost all countries in other traditions have a provision

of other laws override, two thirds of French-tradition countries have it.

136 ｢정부행정｣ 제10권(2014)

Both policy advice exemption and cabinet record exemption are mostly

included in an FOIL of English-tradition countries. The other provisions

unmentioned have almost equal percentage across traditions to make little

significance in the frequency tabulation (low χ2 statistics).

<Table 14> The mean values of dependent variables in terms of FOIL features

FOILfeatures

ATIM=53.12 (s.d=20.89)

Press freedomM=64.23 (s.d=20.71)

TransparencyM=4.96 (s.d=2.32)

SigGroup

SigGroup

SigGroup

YES NO YES NO YES NO

Specificity F=0.78 54.53 50.63 F=0.67 62.51 66.41 F=0.23 4.85 5.11

Constitution F=0.02 53.29 52.53 F=0.33 65.02 61.84 F=0.95 5.11 4.50

Anyone requests F=6.18** 57.52 47.12 F=23.24† 71.17 49.80 F=10.16† 5.53 3.82

Only citizen requests F=1.55 49.69 55.15 F=19.20† 48.55 69.74 F=5.70** 3.94 5.34

Fee F=2.68 55.10 47.13 F=8.62† 59.38 73.22 F=3.31* 4.61 5.62

How to request F=0.11 52.73 54.45 F=0.34 63.39 66.48 F=1.30 4.78 5.47

How to response F=3.38* 54.02 36.60 F=0.06 64.04 65.88 F=0.14 5.00 4.68

Public interest F=2.58 55.66 48.63 F=0.00 64.14 64.35 F=0.16 5.06 4.84

Officials' duty F=3.38* 56.35 48.53 F=3.27* 67.24 58.35 F=4.47** 5.37 4.20

Officials' penalty F=1.47 51.32 56.78 F=4.79** 59.26 69.34 F=10.64† 4.15 5.80

Other laws override F=15.80† 57.37 38.64 F=12.54** 68.06 48.40 F=5.66** 5.27 3.73

Affirmative F=0.37 52.53 55.94 F=0.29 63.50 66.47 F=1.40 4.79 5.53

Policy exemption F=4.87** 59.29 49.68 F=0.91 67.48 62.67 F=1.67 5.47 4.72

Cabinet records F=0.91 48.56 54.02 F=4.40** 73.00 61.56 F=1.43 5.53 4.78

Whistleblower F=3.10* 44.81 54.77 F=2.40 55.36 65.71 F=3.20* 3.76 5.15

*: pr < 0.10, **: pr < 0.05, †: pr < 0.01Note: An individual country belongs to the YES group when its FOIL has a specific provision.

FOIL features do not only present a distinction among legal traditions

but also play a role as determinants for the degree of fulfilling FOI ideals.

In Table 14, anyone request, officers’ duty and other laws override are an

FOIL’s important property to discriminate between the high and the low

level of achieving FOI ideals. The presence of a provision to guarantee

anyone’s request significantly increases scores in ATI, press freedom and

transparency. The index score pattern in the provision to limit a request


to a person with legal citizenship is apparently opposite to that in the

anyone-request provision. Countries where only citizens can request

information have low scores in the indicators of FOI ideals. The absence

of a fee provision enhances press freedom and transparency, but the

provision is not significant in making a difference in the ATI level. How

to respond is significant only in the mean difference of the ATI level.

Informing citizens of FOIL procedures can help enhance the level of access

to government information. Countries with a provision to describe

officials’ duty to publish exhibit higher scores in all FOI ideals than a

group of countries without the provision.

On the other hand, the mean difference in a penalty provision violates

the common-sensical expectation that the stipulation of penalty for

officials would increase the degree of fulfilling FOI ideals. Countries that

do not have the provision in their FOIL are persistently higher in all

dependent variables than countries with it. When an FOIL has a

whistleblower protection, its score for FOI ideals is significantly lower.

These counter-expected findings can attribute to a cross-cultural

discrepancy within a country. Both noncompliance penalties and

whistle-blower protection may only be of value in heterogeneous and

conflicting cultures rather than in homogeneous cultures as in Scandinavian

countries. In addition, the efficacy of an FOIL can be explained by

citizens’ expectation for public officials better than by the complete

presence of relevant legal provisions such as penalty and whistleblower

protection. Citizens in cultures of high FOI ideals tend to expect that

public officials would act not as independent agents but rather as agents

of the electorate. Such expectation enhances the perceived level in

achievement of FOI ideals in a country.

Ironically, the presence of some provisions to limit a scope of an FOIL

displays higher scores in FOI ideals than their absence does. When other

138 ｢정부행정｣ 제10권(2014)

laws can legitimately override an FOIL, scores of FOI ideals are

significantly higher than otherwise. This counter-intuitive pattern also

appears in policy advice exemption and cabinet record exemption.

Differently from the expectation that an exemption provision dampens FOI

ideals, ATI score is higher in a group of countries with a

policy-advice-exemption provision than in countries without the provision.

Likewise, countries with a provision of cabinet record exemption exhibited

higher score of press freedom than countries without the provision.

In the face of significance in several FOI features, the sign of its mean

difference brings an unexpected result. This result may come from an

obvious contrast of German and Scandinavian vs. English and French

tradition. Scores in all three dependent variables are high in German and

Scandinavian legal traditions. Described in Table 13, the two traditions

with overall high scores have FOIL features quite different from English

and French tradition with relatively low scores. For example, the presence

of a whistleblower protection and a penalty provision is expected to

increase scores of FOI ideals; however, German- and

Scandinavian-tradition countries with high mean scores do not have the

provisions in their FOIL. The mean difference between two tradition pairs

(German and Scandinavian vs. English and French) in FOI scores makes a

counter-intuitive result in terms of the absence or presence of a specific

provision.

Ⅴ. Discussions

The aforementioned section explored ideals and realities of an FOIL

through statistical analysis. The simple comparison of FOIL vs. no-FOIL

countries demonstrated a group of countries with an FOIL has


accomplished FOI ideals more than no-FOIL countries. However, the

regression analysis on the panel data overturns the monolithic finding from

the comparison by the mean difference. Whether a country has an FOIL

is not per se a promising indicator for realization of FOI ideals. The

existence of an FOIL may be itself rhetoric, and thus it is not any

guarantee for the ideal reality. Instead, this study confirms the presence of

important determinants for FOI ideals. While the FOIL dummy has little

significance in the panel data models considering influences from years and

countries, the quality of public administration and political stability are

significant predictors for estimating the level of FOI ideals.

On the other hand, legal traditions significantly distinguish high

achievers of FOI ideals from low achievers of them. Countries belonging

to German and Scandinavian tradition are more likely to accomplish FOI

ideals than those with English and French tradition within which the

range of FOI indicator scores is much wider due to cross-national

heterogeneity in diverse contexts of society, culture, and politics.

The final focus was casted on the relationship of statute features with

FOI ideals. Given the intention behind particular provisions, some of

significant differences in FOI ideals scores between countries with a

specific provision and those without it seem to break conventional

wisdom. It is unexpected that countries with exemption provisions have

higher scores of FOI. This counter-intuitive result hints that the degree of

specificity in an FOIL is important. The content of a provision can itself

be consequential, but this study found that concrete and sophisticated

stipulation gains an importance over the intention of a provision. This

finding accords with Gellman’s (1997) argument that one of problems

inherited in the FOIA may come from its poor draft.

140 ｢정부행정｣ 제10권(2014)

Ⅵ. Limitations

Concentrating on methodological concerns, I confess three limitations of

this study. First, it is no doubt that public administration and political

stability have a significant impact on realization of FOI ideals, but this

paper does not consider the independent impact from culture of secrecy in

the public sector and over a whole society. The prevalence of such

culture, to a substantial extent, predetermines the degree to which a

government accomplishes FOI ideals (Banisar, 2006). Considering culture

of secrecy in an empirical study would face methodological difficulties in

measuring culture quantitatively.

Another issue is inherent in a cross-national study whose unit of

analysis is an individual country. If implementation of an FOIL is

problematic, an individual agency is appropriate as a unit of analysis

because the lack of resources such as staff and budget and bureaucratic

attitude unfavorable for FOIL implementation are principal constraints

with an FOIL. However, a researcher confronts difficulty and even

impossibility to survey individual agencies across many countries. For a

cross-national analysis, this study employs a country’s quality of public

administration as if it can reliably represent a single level to aggregate all

governments in each country. This cross-national study assumes that the

general quality of public administration in a country significantly influences

the degree to which the stated goals of its FOIL are achieved. The idea is

not a deviation from the existing insightful albeit non-empirical argument

that administrative discretion and agency culture affect the realization of

the legal ideals. Rather, my assumption is still consistent with the

agency-level arguments because this study extends the scope of public

administration from an individual agency to a national government.

The third issue involves a statistical concern. Although panel data


techniques provide more implicative findings and more accurate estimation

than OLS on the pooled data does, the study lays little attention to high

likelihood of interpenetrations among an FOIL dummy, legal traditions

and FOI reality determinants. Including the interactive variables causes a

problem of soaking up many degrees of freedom, however. A statistically

better analysis, therefore, requires the increase in the number of

observations. Since the number of countries is fixed, the time-series

increase is the way to enlarge the size of the global longitudinal data.

With greater precision of statistical estimation and better-fitting model

specification including interaction terms, an analysis on the larger dataset

in the future needs to revisit implications from this study.

Ⅶ. Conclusions

A freedom-of-information law seeks for making a government

accountable for and transparent to the public by enhancing access to

information. The pursuit of FOI ideals is being realized in some countries,

but other countries use the presence of the law as a symbol of FOI.

Though FOIL countries accomplish FOI ideals more than no-FOIL

countries, the regression analysis on the panel data revealed the skeptic

finding that an FOIL itself is not a promoter to improve access to

information, press freedom and governmental transparency. Both the

quality of public administration and political stability obtain a greater

significance than whether or not a country has an FOIL.

By adding legal heritage dummy variables to regression, I found that

countries with German and Scandinavian traditions are overall reaching

closer to FOI ideals than followers of English and French traditions.

However, this is no more than a general tendency on an average statistic.

142 ｢정부행정｣ 제10권(2014)

The latter heritages have much broader variation in the range of FOI

scores than the former. Socio-cultural heterogeneity across countries within

a larger group of the same legal heritage contributes to the wider range

for estimating the degree to which an individual country accomplishes FOI

ideals.

Some FOIL provisions distinguish high achievers from low achievers of

FOI ideals. Countries that have provisions for anyone request, duty to

publish, noncompliance penalty and other laws override are more likely to

have high scores in FOI ideals indices. However, there is a

counter-intuitive but impressive finding; FOI ideals are more accomplished

in countries that have detailed exemption provisions than in countries

without such provisions. The punch line is that not only the content but

also concreteness of an FOIL makes the law come to the reality beyond

its rhetoric.

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Appendix 1. The list of countries with an FOI law

Country Year passed The formal name of an FOI Law

Albania 1999 The Law on the Right to Information for Official Documents*

Angola 2002 The Law on Access to Documents Held by Public Authorities*

Antigua and Barbuda 2004 Freedom of Information Act 2004

Argentina 2003 Access to Public Information Regulation†

Armenia 2003 The Law on Freedom of Information

Australia 1982 Freedom of Information Act 1982

Austria 1987 Federal Law on the Duty to Furnish Information*

Belgium 1994 The Law on the Right of Access to Administrative Documents*

Belize 1994 Freedom of Information Act

Bosnia and Herzegovina 2001 Freedom of Access to Information Act (FoAIA)

Bulgaria 2000 Access to Public Information Act

Canada 1982 Access to Information Act

Chile 2008 Freedom of Information Act

China 2007Ordinance on Openness of Government Information (OGI regulation)†

Columbia 1985 The Law Ordering the Publicity of Official Acts and Documents*

Cook Islands 2008 Freedom of Information Act

Croatia 2003 The Act on the Right of Access to Information

Czech Republic 1999 The Law on Free Access to Information

Denmark 1970 Access to Public Administration Files Act

Dominican Republic 2004 The Law on Access to Information

Ecuador 2004 Organic Law on Transparency and Access to Public Information

Estonia 2000 Public Information Act

Finland 1951 The Act on the Openness of Government Activities

France 1978 The Law on Access to Administrative Documents

Georgia 1999General Administrative Code of Georgia (Ch 3. Freedom of Information)

Germany 2005 The Act to Regulate Access to Federal Government Information

Greece 1986 The Code of Administrative Procedure

Honduras 2006 Access to Information Law

Hong Kong 1995 The Code on Access to Information†

Hungary 1992Protection of Personal Data and Disclosure of Data of Public Interest

Iceland 1996 Information Act

India 2005 Right to Information Act

Indonesia 2008 The Law Regarding Transparency of Public Information

Ireland 1997 Freedom of Information Act

Israel 1998 Freedom of Information Law

Italy 1990 Law No. 241

Jamaica 2002 Access to Information Act

Japan 1999The Law Concerning Access to Information Held by Administrative Organs

Jordan 2007 The Law on Securing the Right to Information Access

Korea, South 1996 The Act on Disclosure of Information by Public Agencies

Kosovo 2003 The Law on Access to Official Documents

146 ｢정부행정｣ 제10권(2014)

Source: Banisar, D. (2006); Tromp, S. L. (2008)†: The provision (code or regulation) is not the FOI law itself, but plays a part of similar functions. *: The country does not provide the formal name of the law in English.

Kyrgyzstan 2006 The Law on Access to Information

Latvia 1998 The Law on Freedom of Information

Liechtenstein 1999 The Information Act

Lithuania 1999 The Law on the Provision of Information to the Public

Macedonia 2006 The Law on Free Access to Information of Public Character

Mexico 2002The Federal Law of Transparency and Access to Public Government Information

Moldova 2000 The Law on Access to Information

Montenegro 2005 The Law on Free Access to Information

Nepal 2007 Right to Information Act 2007

Netherlands 1978 Government Information (Public Access) Act

New Zealand 1982 Official Information Act

Nicaragua 2007 The Law on Access to Information*

Norway 1970 Freedom of Information Act

Pakistan 2002Ordinance to provide for transparency and freedom of information†

Panama 2001 The Law on Transparency in Public Administration*

Peru 2002 The Law of Transparency and Access to Public Information

Philippines 1987Code of Conduct and Ethical Standards for Public Officials and Employees†

Poland 2001 The Law on Access to Public Information

Portugal 1993 The Law of Access to Administrative Documents (LADA)

Romania 2001 The Law Regarding Free Access to Information of Public Interest

Serbia 2004 The Law on Free Access to Information of Public Importance

Slovakia 2000 The Act on Free Access to Information

Slovenia 2003 Access to Public Information Act (ZDIJZ)

South Africa 2000 Promotion of Access to Information Act (PAIA)

Spain 1992 Law on Rules for Public Administration*

St. Vincent and the Grenadines

2003 Freedom of Information Act

Sweden 1949 Freedom of the Press Act

Switzerland 2004 Federal Law on the Principle of Administrative Transparency

Tajikistan 2002 The Law of the Republic of Tajikistan on Information

Thailand 1997 Official Information Act

Trinidad and Tobago 1999 Freedom of Information Act

Turkey 2003 The Law on Right to Information

Uganda 2005 Access to Information Act 2005

Ukraine 1992 The Law on Information

United Kingdom 2000 Freedom of Information Act 2000

United States 1996 Freedom of Information Act

Uzbekistan 2002The Law on the Principles and Guarantees of Freedom of Information

Zimbabwe 2002 Access to Information and Privacy Protection Act (AIPPA)


Appendix 2. Categorization of countries in terms of legal tradition

Legal traditions

Countries (188)

No-FOI law countries (115) FOI law countries (73)

English(61)

Anguilla, Bahamas, Bahrain, Bangladesh, Barbados, Bermuda, Bhutan, Botswana, Cayman Islands, Cyprus, Dominica, Fiji, Gambia, Ghana, Grenada, Guyana, Kenya, Lesotho, Liberia, Malawi, Malaysia, Maldives, Micronesia, Namibia, Nigeria, Papua New Guinea, Samoa, Saudi Arabia, Sierra Leone, Singapore, Solomon Islands, Sri Lanka, St. Kitts and Nevis, St. Lucia, Sudan, Swaziland, Tanzania, Tonga, United Arab Emirates, Vanuatu, Zambia (41)

Antigua and Barbuda, Australia, Belize, Canada, Hong Kong, India, Ireland, Israel, Jamaica, Nepal, New Zealand, Pakistan, South Africa, St. Vincent and the Grenadines, Thailand, Trinidad and Tobago, Uganda, United Kingdom, United States, Zimbabwe (20)

French(100)

Afghanistan, Algeria, Aruba, Azerbaijan, Benin, Bolivia, Brazil, Burundi, Cambodia, Cameroon, Cape Verde, Central African Republic, Chile, Comoros, Congo Democratic Republic, Congo Republic, Costa Rica, Cote D’Ivoire, Djibouti, Egypt, El Salvador, Equatorial Guinea, Eritrea, Ethiopia, Gabon, Guatemala, Guinea, Guinea-Bissau, Haiti, Indonesia, Iran, Iraq, Kazakhstan, Kuwait, Laos, Lebanon, Luxembourg, Macao, Madagascar, Mali, Malta, Mauritania, Mauritius, Morocco, Mozambique, Netherlands Antilles, Niger, Oman, Paraguay, Puerto Rico, Qatar, Russia, Rwanda, Sao Tome and Principe, Senegal, Seychelles, Suriname, Syria, Togo, Tunisia, Turkmenistan, Uruguay, Venezuela, Vietnam, Yemen (68)

Albania, Angola, Argentina, Belgium, Colombia, Dominican Republic, Ecuador, Estonia, France, Greece, Honduras, Italy, Jordan, Kyrgyzstan, Lithuania, Macedonia, Mexico, Moldova, Montenegro, Netherlands, Nicaragua, Panama, Peru, Philippines, Portugal, Romania, Serbia, Spain, Tajikistan, Turkey, Ukraine, Uzbekistan (32)

German(19)

Belarus, Mongolia, Taiwan (3) Austria, Bosnia-Herzegovina, Bulgaria, China, Croatia, Czech Republic, Georgia, Germany, Hungary, Japan, Korea South, Latvia, Poland, Slovakia, Slovenia, Switzerland, (16)

Scandinavian(5)

Denmark, Finland, Iceland, Norway, Sweden (5)

Socialism (3)

Cuba, Korea North, Myanmar (3)

148 ｢정부행정｣ 제10권(2014)

Appendix 3. The list of countries included in Global Integrity Index

(ATI variables)

Year Countries

2004(25)

Argentina, Australia, Brazil, Germany, Ghana, Guatemala, India, Indonesia, Italy, Japan, Kenya, Mexico, Namibia, Nicaragua, Nigeria, Panama, Philippines, Portugal, Russia, South Africa, Turkey, Ukraine, United States, Venezuela, Zimbabwe

2006(41)

Argentina, Armenia, Azerbaijan, Benin, Brazil, Bulgaria, Congo Democratic Republic, Egypt, Ethiopia, Georgia, Ghana, Guatemala, India, Indonesia, Israel, Kenya, Kyrgyzstan, Lebanon, Liberia, Mexico, Montenegro, Mozambique, Nepal, Nicaragua, Nigeria, Pakistan, Philippines, Romania, Russia, Senegal, Serbia, Sierra Leone, South Africa, Sudan, Tajikistan, Tanzania, Uganda, United States, Vietnam, Yemen, Zimbabwe

2007(50)

Algeria, Argentina, Armenia, Azerbaijan, Bangladesh, Bosnia-Herzegovina, Bulgaria, Burundi, Cameroon, Canada, China, Colombia, Costa Rica, Ecuador, Egypt, France, Georgia, India, Italy, Japan, Jordan, Kazakhstan, Kenya, Kyrgyzstan, Latvia, Lebanon, Malawi, Mexico, Moldova, Mozambique, Namibia, Nepal, Nigeria, Pakistan, Peru, Philippines, Romania, Russia, Sierra Leone, Spain, Sri Lanka, Tajikistan, Tanzania, Thailand, Timor-Leste, Turkey, Uganda, Ukraine, United States, Vanuatu

2008(46)

Angola, Argentina, Azerbaijan, Bangladesh, Belarus, Bosnia-Herzegovina, Bulgaria, Cameroon, Canada, Chile, China, Colombia, Ecuador, Egypt, Ethiopia, Georgia, Ghana, Hungary, Indonesia, Iraq, Italy, Japan, Kazakhstan, Kenya, Kyrgyzstan, Lithuania, Macedonia, Moldova, Montenegro, Morocco, Nepal, Nicaragua, Nigeria, Pakistan, Philippines, Poland, Romania, Russia, Serbia, Somalia, South Africa, Turkey, Uganda, West Bank Gaza, Yemen

Paneldata(84)

Algeria, Angola, Argentina, Armenia, Azerbaijan, Australia, Bangladesh, Belarus, Benin, Brazil, Bosnia-Herzegovina, Bulgaria, Burundi, Cameroon, Canada, Chile, China, Colombia, Congo Democratic Republic, Costa Rica, Ecuador, Egypt, Ethiopia, France, Georgia, Germany, Ghana, Guatemala, Hungary, India, Indonesia, Iraq, Israel, Italy, Japan, Jordan, Kazakhstan, Kenya, Kyrgyzstan, Latvia, Lebanon, Liberia, Lithuania, Macedonia, Malawi, Mexico, Moldova, Montenegro, Morocco, Mozambique, Namibia, Nepal, Nicaragua, Nigeria, Panama, Pakistan, Peru, Philippines, Poland, Portugal, Romania, Russia, Senegal, Serbia, Sierra Leone, Somalia, South Africa, Spain, Sri Lanka, Sudan, Tajikistan, Tanzania, Thailand, Timor-Leste, Turkey, Uganda, Ukraine, United States, Vanuatu, Venezuela, Vietnam, West Bank Gaza, Yemen, Zimbabwe

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